Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Supplementary memorandum by the Campaign to Protect Rural England (CPRE) (AH 57(a))


  1.  At the end of the second evidence session for this inquiry on 6 December the Chairman invited CPRE to submit a written response to the question "Do local planning authorities have sufficient power to ensure housing is built to high environmental standards?" This note addresses that question.

  2.  We would also like to take this opportunity to clarify CPRE's position on the issue of housing numbers and development plans, as well as to raise questions about the implications of draft Planning Policy Statement (PPS) 3 Housing which was issued for consultation the day before the Committee's second evidence session.

"Do local planning authorities have sufficient power to ensure housing is built to high environmental standards?"

  3.  CPRE does not believe that planning authorities have sufficient powers in this area. Some local authorities may have a better record than others but we do not believe that recent Government pronouncements are likely to achieve very much by way of improving performance across the board. Indeed, we fear that the current proposals could actually lead to a deterioration in the ability of local authorities to require high environmental standards in the provision of new housing. This could make the environmental `footprint' of new housing extend much further than it currently does, as well as reducing the long term affordability of running a home to the detriment of those on low or moderate incomes.

  4.  Draft PPS 3 is particularly weak in this regard. For example, it contains a section on "greening the residential environment" but this places no requirements on local authorities to ensure this is delivered on the ground. The draft PPS merely states that "local planning authorities should encourage applicants to apply principles of sustainable and environmentally friendly design and construction", and, in particular, to encourage them "to apply the proposed Code for Sustainable Homes" (paragraph 39).

  5.  Given the Government's apparent intention to rely largely on private, market housing to address what is sees as the shortage in supply, it is disturbing that it is proposing to make the Code for Sustainable homes voluntary for private development (ie that which does not enjoy public funding). We believe that applying sound principles of sustainable and environmentally-friendly design and construction to new housing development should be mandatory, not optional. This will be essential if we are to meet commitments in the UK Strategy for Sustainable Development. It will also be essential for the Code to cover a wider range of issues. We believe it should, as a minimum, incorporate assessment of:

    —  materials sourcing (eg aggregates: whether primary, secondary or recycled/re-used, distance transported to the sites and by what means of transport);

    —  accessibility to public transport (and preferably also to the potential for households' daily needs to be met on foot); and

    —  ecological impact.

  6.  In addition to these issues, CPRE notes that WWF has recently expressed a fear that the proposed Code, as currently drafted, could actually lower the standards currently required of new, publicly funded housing.

  7.  There is a particular difficulty in securing high environmental standards in new housing because certain important matters fall under building regulations (eg thermal efficiency) and others under planning controls (eg the external design of buildings, layout and orientation of development on site), but all significantly affect environmental performance. PPS1, issued earlier this year, states that planning policy should not overlap with matters dealt with under other legislation or administered by different regimes (eg building control). We strongly believe that this position has become a real barrier to progress. There is also anecdotal evidence (as recently discussed by the Environmental Audit Committee as part of its current inquiry) that the effectiveness of Building Control regulations is being affected by a shortage of resources and skills, pressure to cut costs and a lack of enforcement. An integrated approach is urgently needed, especially since building control is often a relatively late consideration in the development and planning process. This could help co-ordinate and combine planning and building controls in order to achieve the higher environmental standards which are so necessary.


  8.  We would like to add a point of clarification on our view as to the number of new homes that are needed in England. We strongly support the plan-led system, through Regional Spatial Strategies (RSSs) and Local Development Frameworks (LDFs), as a basis for agreeing the number of homes that should be built and their distribution. Hence, the reference in our oral evidence to the 170,000 homes provided for in adopted/emerging Regional Spatial Strategies as representing a level of annual housing supply we could broadly subscribe to.

  9.  CPRE will not always agree with the precise figures arrived at in every region, and there will inevitably be issues concerning the distribution and precise balance between brownfield and greenfield development. We firmly believe, however, that if the plan-led system is to be credible, effective and command public confidence any proposed changes in the levels of housing provision should come forward—and be subject to rigorous examination—through the established process. The Government's new planning system lays great emphasis on the importance of a credible evidence-base for policy and decisions, something we strongly support. "Targets" for housing supply imposed from the centre, with little or no reference to contextual evidence of need and environmental implications, are inconsistent with this approach. Their effect is not only misguided, but actively damaging to the integrity of the plan-led system.

  10.  We consider that projected household growth should be taken into account in determining housing provision. Household formation should not be seen as directly correlating with the number of new homes needed, however, since it is important to compare the total number of households with the dwelling stock, as well as to take into account other objectives. In particular, we need more effective action to reduce the number of empty homes (and particularly the 300,000 or so long term empty properties), consider scope for conversions from other types of buildings, and reduce levels of under-occupancy. Before building new homes. we need to make much better use of the potential offered by these sources.


  11.  We would also like to urge the Select Committee to consider including an assessment of draft PPS3, published on 5 December, in its deliberations. From our initial reading of the draft we believe that certain important aspects would benefit from the Committee's scrutiny. We suggest the Committee considers holding a further evidence session under the current inquiry, or a further inquiry, to consider draft PPS 3. In our view, key issues to address include:

    —  questions over the practical application of the clear priority for brownfield over greenfield sites, set out in the draft and reinforced in comments by the Planning Minister on its launch, given the proposed removal of local authorities' ability to phase release of sites in the first five years of planned provision;

    —  tensions between the Government's priority for brownfield sites and the explicit discouragement of local authorities from making assumptions regarding the supply of housing on (brownfield) windfall sites, and how these could be resolved;

    —  whether the proposed return to a five-year housing land supply rule risks a regression to "planning by appeal" which plagued planning for housing prior to publication of revised PPG3 in 2000, and how this could be avoided;

    —  whether, given the large proportion of new housing now built on small urban sites, the retention of an indicative site threshold for affordable housing requirements will significantly reduce the potential supply of affordable housing, and whether abolition of thresholds altogether would be preferable;

    —  what needs to be done to ensure that Sustainability Appraisal of plan documents and site allocations is sufficiently effective and robust to deliver genuinely sustainable patterns of development; and

    —  issues surrounding the proposed sub-regional Housing Market Areas: draft PPS3 includes a table illustrating how different approaches might apply in different Housing Market Areas but appears to excludes the possibility that in some areas of high demand, such as Areas of Outstanding Natural Beauty, a low or no growth option which focuses on meeting local needs might be the most appropriate way forward.

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